Southwest Gas proceeding

You have asked me to outline the argument that would be used in requesting a
motion to expedite the Commission's decision in this proceeding. The motion
would be filed pursuant to Rule 212 of the Commission's Rules of Practice and
Procedure, which simply allows parties to file motions. Sempra is not yet a
party, so it would have to include in its pleading a motion to intervene out
of time. The Commission may grant late interventions pursuant to Rule 214 if
the movant has good cause for failing to file the motion on time, permitting
the intervention will cause no significant disruption of the proceeding, the
movant's interest is not adequately represented by other parties in the
proceeding, and no prejudice to other parties would result from granting late
intervenor status. Additionally, like other intervenors, Sempra must also
explain its interest in the proceeding, including why it has a right to
participate, why it could be directly affected by the outcome of the
proceeding, and that its participation in the proceeding would be in the
public interest. (We've seen numerous interventions by Sempra and they have
some standard language they use in their interventions to describe the
company and request intervenor status).

The basis for requesting expedited status of the SWGas application would be
that Sempra's Gallup Expansion transport agreement includes a provision